This guide, 'How To Draft An Electronic Disclosure Production Protocol', is prepared by Computer Forensics Lab's e-discovery team for UK lawyers.
Guide · 17 pages · 21 min read · Published 2026-08-30
This guide, 'How To Draft An Electronic Disclosure Production Protocol', is prepared by Computer Forensics Lab's e-discovery team for UK lawyers. It covers the agreement that decides every later argument, clause by clause. The guide details where the protocol sits, referencing the DRD and PD 57AD, and when to agree it. It addresses format clauses, including natives, images, and the per-type schedule, alongside data clauses such as metadata fields, families, threading, and load files. Protection clauses - redaction, privilege, clawback, and confidential it y-are discussed, as are operations clauses covering exchange, tranches, corrections, and disputes. The guide also explores source architecture, common mistakes, technical limitations, and provides questions to ask and suggested wording for the protocol's core skeleton. It includes a checklist, red flags, and advice on when to involve a digital forensic expert. This resource is for litigators, in-house counsel, and investigators seeking to prevent expensive, late disputes through a cheap, early agreement.
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17 pages · 21 min read
This guide, 'How To Draft An Electronic Disclosure Production Protocol', is prepared by Computer Forensics Lab's e-discovery team for UK lawyers.
Published by Computer Forensics Lab on 2026-08-30. Original material of the practice, free to read, cite and download. The authority behind this subject is Practice Direction 57AD, Disclosure in the Business and Property Courts, which you should read alongside this guide. See every guide's author and source.
Prefer a PDF that matches this page exactly? Download the current text as a PDF, generated from the wording shown here, including any later corrections.
PRODUCTION PROTOCOL S · A GUIDE FOR UK LAWYERS How to Draft an Electronic Disclosure Production Protocol The Agreement That Decides Every Later Argument, Clause by Clause COMPUTER FORENSICS LAB
§ ABOUT THE AUTHOR PREPARED BY COMPUTER FORENSICS LAB E-DISCOVERY TEAM ESTABLISHED 2007 · LONDON ISO 17025-ALIGNED PROCEDURES FULL CHAIN-OF-CUSTODY DOCUMENTATION
§ CONTENTS In this guide 01 Executive summary 02 The problem in plain English: the argument you have now or the ten you have later 03 Where the protocol sits: the DRD, PD 57AD and when to agree it 04 The format clauses: natives, images, and the per-type schedule 05 The data clauses: metadata fields, families, threading and load files 06 The protection clauses: redaction, privilege, clawback and confidential it y 07 The operations clauses: exchange, tranches, corrections and disputes 08 Source architecture: where else the evidence lives 09 Worked examples 10 Common mistakes and technical limitations 11 Questions to ask · Suggested wording 12 Checklist and red flags · When to involve a digital forensic expert 13 Frequently asked questions 14 Glossary · References · Disclaimer · How a specialist laboratory can assist
§ 01 · ORIENTATION Executive summary THE HEADLINE POINT: APRODUCTIONPROTOCOLISTHECHEAP, EARLY AGREEMENT THATPREVENTSTHEEXPENSIVE, LATEDISPUTES: DRAFTITWITHTHEENGINEERSIN THEROOM, TESTITAGAINSTTHEKNOWNDISASTERS, ANDAGREEITBEFORETHEFIRST TRANCHEISBUILT
§ 02 · FIRST PRINCIPLES The problem in plain English: the argument you have now or the ten you have later
§ 03 · THEFRAME Where the protocol sits: the DRD, PD 57AD and when to agree it
§ 04 · FORMATS The format clauses: natives, images, and the per-type schedule
§ 05 · DATA The data clauses: metadata fields, families, threading and load files
§ 06 · PROTECTIONS The protection clauses: redaction, privilege, clawback and confidential it y
§ 07 · OPERATIONS The operations clauses: exchange, tranches, corrections and disputes
§ 08 · THEWIDERMAP Source architecture: where else the evidence lives QUESTION PROTOCOL CORRECTION DATA PROCESSING PLATFORM MANIFESTS + MAP DESIGN CAPABILITIES RECONCILIATIONS SIGNED DEFECT + + VERSIONS LOG
§ 09 · IN THE WILD Worked examples EXAMPLE1 · THETEMPLATESIGNEDUNREAD EXAMPLE2 · THESAMPLEEXCHANGETHATPAIDFORTHEYEAR EXAMPLE3 · THEDISPUTELADDERTHATKEPTTHEDELIMITEROUTOFCOURT
§ 10 · WHEREITGOESWRONG Common mistakes and technical limitations Common mistakes Technical limitations
§ 11 · INTERROGATORIES & DRAFTING AIDS Questions to ask · Suggested wording Ask your client Ask your opponent Ask your e Discovery / forensic provider SUGGESTED WORDING · CORESKELETONFORTHEPROTOCOL
§ 12 · QUICK CONTROL Checklist and red flags · When to involve a digital forensic expert The protocol drafting checklist Red flags When to involve a digital forensic expert
§ 13 · COMMON QUESTIONS Frequently asked questions Is a production protocol actually required? When should the protocol be agreed? The other side sent their standard protocol. Can we just sign it? What belongs in the protocol versus the DRD's other sections? What if a data type turns up that the protocol never contemplated? How detailed should the load-file specification really be?
§ 14 · REFERENCE Glossary Sources and authoritative references DISCLAIMER
§ HOW A SPECIALIST LABORATORY CAN ASSIST Working with Computer Forensics Lab Speak to a forensic examiner, not a salesperson. INSTRUCTTHELAB NEWENQUIRIESEMAILE - DISCOVERY
45 pages · 86 min read
Whether you are responding to a regulator, preparing for disclosure, or scoping an internal investigation, start the chain of custody with a short, confidential conversation.
